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levy action. Sec. 6330(c)(3). A hearing officer may rely on a
computer transcript or Form 4340, Certificate of Assessments,
Payments, and Other Specified Matters, to verify that a valid
assessment was made and that a notice and demand for payment was
sent to the taxpayer in accordance with section 6303. Nestor v.
Commissioner, 118 T.C. 162, 166 (2002); Schaper v. Commissioner,
T.C. Memo. 2002-203; Schroeder v. Commissioner, T.C. Memo. 2002-
190. Absent a showing of irregularity, a transcript that shows
such information is sufficient to establish that the procedural
requirements of section 6330 have been met. Nestor v.
Commissioner, supra at 166-167.
Section 6330(d)(1) grants the Court jurisdiction to review
the determination made by the Appeals officer at the hearing.
Where the underlying tax liability is not in dispute, the Court
will review the determination of the Appeals Office for abuse of
discretion. Lunsford v. Commissioner, 117 T.C. 183, 185 (2001);
Sego v. Commissioner, supra at 610; Goza v. Commissioner, 114
T.C. 176, 182 (2000).
In this case, the undisputed facts set forth in respondent’s
motion, declarations in support of the motion, and attached
exhibits establish that respondent has satisfied the requirements
of section 6330. Mr. Climan took into consideration all of the
factors required by section 6330(c)(3) and rejected petitioner’s
arguments as either frivolous or irrelevant.
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